Your privacy is important to us. Ginzamarkets, Inc. (“Ginzametrics” or “we”) are providing this Privacy Policy (the “Policy”) to describe and explain our online information practices and the choices you can make about the way your information is collected and used. By using www.ginzametrics.com (the “Site”), our services or our products, you consent to the processing of information as set forth herein. If you create an account for our services (a “Business Customer”), we provide hosted software to relating to each Business Customer’s employees, consumers, patients, students, donors, volunteers, clients, supplies and other business partners (“data subjects”) around the world.

This Policy also describes the way we collect, use and disclose certain personal data we receive in the United States from the European Union and Switzerland (“EU and Swiss Personal Data”). With regard to EU and Swiss Personal Data of data subjects of Business Customers, we operate as a data processor, while the Business Customer functions as a data controller. For more information about Safe Harbor Principles or to access our certification statement, please review the U.S. Department of Commerce’s Web site at http://export.gov/safeharbor/.

Information Gathering

When you register with us, we collect “Personally Identifiable Information,” such as your name, company name, email address, billing address and if payment is required for your plan, credit card information. We collect the e-mail addresses if you communicate with us via e-mail or volunteer information through means such as surveys. We use standard methods of verification and procedure to ensure that the data you provide us is reliable for its intended use, accurate, complete and current.

We also collect aggregate, non-personally identifiable information.

For Business Customers, we operate under the assumption that it is generally the Business Customer’s obligation as data controller to notify individuals about the purposes for which they collect and use information about the data subjects, how data subjects can contact the Business Customer with any inquiries or complaints, the types of third parties to which the Business Customer discloses such information, and the choices and means the Business Customer offers for limiting use and disclosure of the information. As a data processor for a Business Customer, we make available this privacy policy so that each Business Customer can better understand our data practices and whether they are consistent with privacy notices such Business Customer has made available to its data subjects. We only collect the information about a Business Customer’s data subjects that such Business Customer provides to us or directs us to collect (“Customer Information”). We may obtain EU and Swiss Personal from data subjects regarding name, postal address, e-mail address, phone number, as well as information relating to payment-card, personal health, clinical-trial data, demographics, purchase history, market-research, employee and student performance and any information a Business Customer may send or direct us to collect from third parties at such Business Customer’s direction. We do not control what Customer Information we receive and host, nor what steps a Business Customer as data controller has taken to ensure that the data is reliable for its intended use, accurate, complete and current.

Information Usage

Ginzamarkets uses Personally Identifiable Information and Customer Information for the following general purposes:

to provide our products and services,

for billing, identification and authentication,

to analyze Site usage and improve our products and services,

to contact you and deliver administrative notices and communications relevant to your use our products and services,

for internal market research, troubleshooting problems, and detecting and protecting against error, fraud or other criminal activity,

for distribution to third-party contractors that provide services to Ginzametrics and are bound by privacy restrictions at least as restrictive as those set forth in this Policy,

to enforce our Terms of Use, and

as otherwise set forth in the Policy.

The Personally Identifiable Information we collect is used to improve the content of our Site and the quality of our service, and is not shared with other organizations, except to provide or improve upon products or services that you’ve requested, or under the following circumstances: it is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law.

We do NOT sell or rent any of your Personally Identifiable Information.

We may disclose non-personally identifiable information to third parties for research, marketing and other purposes.

We reserve the right to transfer any and all information that we collect to an affiliate, subsidiary, or third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or part of our business, assets or stock. We will use our best efforts to ensure that the new entity follows the Policy with respect to your personal information, as and to the extent required by applicable law.

Cookies

A “Cookie” is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive.

We use session Cookies (which expire once you close your web browser), but not persistent Cookies (which stay on your computer until you delete them) to provide our services to you, and to advertise to you on our Site or elsewhere, based on your prior visits to our Site. You can set your browser to deny Cookies, but this will not allow you to use the Site, or our products or services.

Web Beacons

A “Web Beacon” is an electronic image, called a single-pixel (1×1) or clear GIF that recognizes certain types of information on your computer, such as your cookie number, time and date of a page view and description of the visited page. We may use “Web Beacons” through the Site or html-formatted emails in order to compile aggregate statistics about Site usage. You may render some Web Beacons inactive by rejecting their associated Cookies.

Data Storage and Protection

Our safeguards and procedures have been implemented in accordance with applicable law to maintain the physical and electronic security of our software, services and your personal information. Our measures include firewalls, system-wide data encryption, physical and electronic access controls, and strict rules regarding the access and use of data on our system. We require you to log back into your account after a certain period of time has elapsed to protect against others unauthorized access of your account. If we confirm that a Business Customer’s Customer Information has been accessed or used by unauthorized individuals, we will contact your designated representative to coordinate our response to the incident. We limit retention of Personally Identifiable Information to no longer than commercially necessary to carry out its business purpose, or for legitimate law enforcement purposes.

Personally Identifiable Information or Customer Information collected on our systems may be transferred across state and country borders and stored or processed in the United States or any other country in which Ginzametrics, its affiliates, or business partners maintain facilities for the purposes of data consolidation, storage, and information management. By using our systems, your consent to any such transfer of information outside of your country of residence. Such transferred Personally Identifiable Information or Customer Information shall be handled in the manner described here, even if the laws in some countries may provide less protection for such information. Our privacy practices are designed to protect your personal information all over the world.

It is a Business Customer’s obligation as to ensure that their treatment of any personally-identifiable protected health information (“PHI”) is compliant with the Health Insurance Portability and Accountability Act of 1996 (“HIPPA”). Under our current business model, we have no direct interaction with a Business Customer’s data subjects for whom we may have PHI and cannot ensure that this data was collected or used in a HIPAA-compliant manner. It is a Business Customer’s obligation to notify us if any Customer Information is PHI and we disclaim all liability and the Business Customer assumes all liability relating to our treatment of PHI that a Business Customer does not notify us is PHI. If so notified, we will only use PHI as directed by the Business Customer and will immediately notify such Business Customer if any PHI is inadvertently released and will be responsible for such PHI while it is in our control.

External Links

Links to third-party websites from this website are provided solely as a convenience to you. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control them, nor do we assume responsibility for any of these sites, their content, or their privacy policies. Ginzametrics does not endorse or make any representations about them or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites linked to this Site, you do so at your own risk.

Choice/Opt-Out

Ginzametrics offers you the choice of receiving different types of communication and information related to our company, products and services. You may subscribe to e-newsletters or other publications; you may also elect to receive marketing communications and other special offers from us via e-mail. If at any time you would like to change your communication preferences, we provide unsubscribe links and an opt-out mechanism for your convenience. You may also access and manage your preferences from your account.

The U.S.-EU Safe Harbor requires that members offer end users a choice to opt out of uses and disclosures of their data that are incompatible with the purposes for which that data was originally collected or subsequently authorized. It is a Business Customer’s obligation as data controller to obtain from its data subjects the appropriate consent to transfer such data to us and to process such data using our products for defined purposes. As a Business Customer’s data processor, we will not share, sell, rent, or trade with third parties for their marketing purposes any Customer Information collected by us, unless the Business Customer directs us to do so.

Data Access

If you would like access to personal information about you that we hold, or correct, amend, or delete that information where it is inaccurate, please contact privacy@ginzametrics.com Privacy Manager, Ginzamarkets, Inc., 444 Castro Street, 12th Floor, Mountain View, CA 94041.

We operate under the assumption that it is generally the obligation of a Business Customer as data controller to provide their data subjects a means of accessing their data. Under our current business model, we have no direct interaction with a Business Customer’s data subjects and so have no direct way for them to submit data-access requests to us. If a Business Customer receives a data-access request from a data subject about whom we host data and would like our assistance in responding to that request, please contact privacy@ginzametrics.com Privacy Manager, Ginzamarkets, Inc., 444 Castro Street, 12th Floor, Mountain View, CA 94041.

US-EU and US-Swiss Safe Harbor Framework

Ginzametrics complies with the US-EU Safe Harbor Framework and the US-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Ginzametrics has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification, please visit http://export.gov/safeharbor/.

In compliance with the Safe Harbor Principles, we commit to resolve complaints about your privacy and our collection or use of your personal information. European Union citizens with inquiries or complaints regarding this privacy policy should contact us at privacy@ginzametrics.com or Privacy Manager, Ginzamarkets, Inc., 444 Castro Street, 12th Floor, Mountain View, CA 94041.

Ginzametrics will review all audit requests submitted in writing or through email for the purpose of determining whether or not its procedures and protocols being used are consistent with the US-EU Safe Harbor Framework. It is our policy to routinely monitor and check our compliance procedures and protocols. Should Ginzametrics determine inconsistency with any such procedures or protocol, we will take necessary steps to address and correct the inconsistency. If we are unable to resolve the conflict with the individual or customer/client filing the complaint, we will mediate such said conflict in front of a panel of the American Arbitration Association. Ginzametrics will self certify with the Department of Commerce for the purpose of renewing its Safe Harbor Privacy Policy on an annual basis and confirming its continued commitment to the protection and privacy of personal data.

Changes

Ginzamarkets may periodically update this policy. We will notify you about significant changes in the way we treat personal information by sending a notice to the primary email address specified in your Ginzametrics primary account holder account or by placing a prominent notice on our site.